Search - ”资源化利用" resource

Results 1 - 10 of 63 for ”资源化利用" resource

Dare Human Resources – Ontario Court of Appeal finds that placement agencies were the workers’ employers

15 January 2020- 11:32pm Dare Human Resources – Ontario Court of Appeal finds that placement agencies were the workers’ employers Email this Content Two Ottawa placement agencies supplied temporary workers to the Public Service of Canada and federal agencies. ... Summary of Dare Human Resources Corporation v. Ontario (Revenue), 2019 ONCA 549 under Reg. 100(1) – employer. ...

Burlington Resources – Crown abandons its position that s. 247(2)(c) applied to reduce guarantee fees paid by a ULC to its non-resident parent

23 February 2020- 11:44pm Burlington Resources – Crown abandons its position that s. 247(2)(c) applied to reduce guarantee fees paid by a ULC to its non-resident parent Email this Content Burlington, a Nova Scotia ULC, borrowed approximately U.S.$3 billion in 2001 and 2002 by issuing notes that were guaranteed by its non-resident parent (“BRI”). ... Summary of Burlington Resources Finance Company v. The Queen, 2020 TCC 32 under Rule 132. ...

Burlington Resources Finance – Tax Court of Canada states that taking discovery questions “under advisement” should stop

17 August 2017- 8:23am Burlington Resources Finance – Tax Court of Canada states that taking discovery questions “under advisement” should stop Email this Content CRA disallowed, in full, under s. 247(2)(a), the deduction by Burlington of guarantee fees paid to its U.S. parent. ... Summary of Burlington Resources Finance Company v. The Queen, 2017 TCC 144 under Tax Court of Canada Rules (General Procedure), s. 95(2), s. 107(1). ...

Resource Capital Fund IV LP – Full Federal Court of Australia finds that the effecting of a share sale pursuant to an Australian Scheme of Arrangement pointed to an Australian source

21 April 2019- 11:41pm Resource Capital Fund IV LP – Full Federal Court of Australia finds that the effecting of a share sale pursuant to an Australian Scheme of Arrangement pointed to an Australian source Email this Content Two Caymans investment LPs with mostly U.S. ... That arrangement took place in Australia, and accordingly, because the scheme was the “proximate” origin of the profits earned, and because of the other connections with Australia summarised by the primary judge … including the location of the mine in Western Australia, those profits had a source in Australia. ... Summaries of Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51 under s. 152(1), s. 115(1)(a)((ii) and s. 248(1) – taxable Canadian property – para. ...

Barejo – Federal Court of Appeal states that determining whether the notes in Barejo were debt for purposes of the ITA rather than s. 94.1 would be “an improper use of judicial resources”

1 December 2016- 12:09am Barejo – Federal Court of Appeal states that determining whether the notes in Barejo were debt for purposes of the ITA rather than s. 94.1 would be “an improper use of judicial resources” Email this Content The Federal Court of Appeal has dismissed the Barejo appeal – but on the grounds that the Rule 58 question posed to the Tax Court was whether the “notes” in question were debts for purposes of the Act rather than for purposes of s. 94.1 thereof. ... “that endeavouring to dispose [of] the appeals on the merits would serve no useful purpose and give rise to an improper use of judicial resources.” ...

RCF IV – Federal Court of Australia finds that gains of U.S. limited partners from sales of an Australian resource company were not Treaty exempt but were not TCP-type gains

19 February 2018- 9:19pm RCF IV – Federal Court of Australia finds that gains of U.S. limited partners from sales of an Australian resource company were not Treaty exempt but were not TCP-type gains Email this Content Two Caymans investment LPs (“RCF IV” and RCF V”) whose limited partners were mostly U.S. residents, realized gains from the disposal of shares of significant shareholdings in a TSX-listed Australian corporation (Talison Lithium) which, through a grandchild corporation, held mining leases in Australia and carried out an operation there of mining lithium ores and processing them. ... Summaries of Resource Capital Fund IV LP v Commissioner of Taxation [2018] FCA 41 under Treaties – Income Tax Conventions – Art. 3, Art. 13, s. 248(1) – taxable Canadian property – (d), s. 115(1)(a)(ii), s. 9 – capital gain. v. profit – shares, General Concepts – stare decisis, s. 152(1). ...

Alta Energy – Supreme Court of Canada finds that Treaty shopping to avoid capital gains tax on Canadian resource assets was contemplated, and not a Treaty abuse

28 November 2021- 11:20pm Alta Energy – Supreme Court of Canada finds that Treaty shopping to avoid capital gains tax on Canadian resource assets was contemplated, and not a Treaty abuse Email this Content Two US firms transferred their investment in a Canadian subsidiary (Alta Canada), that was to develop a shale formation in northern B.C., to a Luxembourg s.à r.l. ... Canada “could also have insisted on a subject-to-tax provision” under which it would forego its right to tax capital gains only if the other state actually taxed those gains – but did not. ... Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 under s. 245(4), Treaties – Income Tax Conventions, Art. 4, Statutory Interpretation- Treaties. ...

CRA finds that an Alberta coniferous tree-harvesting right was a timber resource property

13 March 2018- 1:28am CRA finds that an Alberta coniferous tree-harvesting right was a timber resource property Email this Content Rather than reviewing the quite complex jurisprudence on what is a timber resource property, CRA looked at a timber removal right that was effectively a renewal of some timber removal rights that had been granted by the Alberta government in 1967 and 2004, and simply stated: Based on jurisprudence … and the facts and assumptions described above, the New Quota (whether it is viewed as a single property or a combination of two properties) would qualify as a timber resource property pursuant to the definition of that term in subsection 13(21). ... Summary of 6 February 2018 External T.I. 2017-0732151E5 under s. 13(21) – timber resource property. ...

CRA finds that resource royalties payable under a federal statute generally are deductible in computing business income

31 October 2018- 12:09am CRA finds that resource royalties payable under a federal statute generally are deductible in computing business income Email this Content S. 18(1)(m), which generally prohibited the deduction of resource royalties, was repealed over 10 years ago – but is their deduction nonetheless prohibited by s. 18(1)(a)? CRA stated, regarding royalties paid under the Canada Petroleum Resources Act (Canada): [T]he amount of [such] royalties … is not subject to that restriction because, inter alia, if it were not paid, a taxpayer could lose the opportunity to carry on its business and thereby earn income … [and such amount] is generally deductible in computing the business income of a taxpayer. ... Summary of 27 June 2018 External T.I. 2018-0742881E5 F under s. 18(1)(a) – income-producing purpose. ...

It is proposed that Whitecap Resources acquire all the shares of Veren on a s. 85.1 exchange

28 April 2025- 1:39am It is proposed that Whitecap Resources acquire all the shares of Veren on a s. 85.1 exchange Email this Content It is proposed that, under an Alberta Plan of Arrangement, all of the outstanding shares of Veren will be exchanged, generally on a s. 85.1 rollover basis, for shares of Whitecap Resources on the basis of 1.05 Whitecap shares for each Veren share. ... Summary of 28 March 2025 joint Management Information Circular of Whitecap Resources Inc. and Veren Inc. under Mergers & Acquisitions – Mergers – Share for Share. ...

You are here